3rd March 2014
The Bat Conservation Trust (BCT) requests an urgent review of the impacts of HS2 on roosting, commuting and foraging habitat loss on the population viability of all bat species and in particular the susceptibility of the Bechstein's bat population.
HS2 is a government funded scheme and it should be an exemplar of best practice, not only of civil engineering, but also of managing and successfully mitigating any adverse impacts on the natural environment. Having reviewed the Environmental Statement (ES) we are concerned not only that it does not comply with the Sustainability Policy outlined but also that it does not comply with the requirements of UK legislation and best practice guidance that acts to protect bats.
Populations of one of our most strongly protected and nationally important species, the Bechstein's bat, and their supporting habitat (ancient woodland) will be significantly impacted by the HS2 proposals. Bechstein's bat, one of our rarest bat species, is reliant on ancient woodland (defined as those areas that have been continuously wooded since 1600) for both roosting and foraging, which makes it very sensitive to the loss and fragmentation of such habitats. One of our major concerns is that irreplaceable ancient woodland will be lost and we do not consider it possible to compensate for their loss in a 'like for like' manner with newly planted woodlands. A complex habitat such as ancient woodland cannot simply be recreated and this is acknowledged within the ES, which states that 'Ancient woodland is irreplaceable'.
Bats and other species that are heavily reliant on woodland require ongoing foraging resources in order to survive. It is incorrect to make statements suggesting that the time lag between new planting and the point at which vegetation has matured constitutes a temporary impact.
It is imperative that the cumulative impacts of the project are more thoroughly assessed, taking into account the timescales required for new habitats to develop and the likely impacts of this on species that are reliant upon these habitats.
Furthermore, it is acknowledged within the ES that bat roosts will be destroyed during the construction of HS2 and their replacement has been considered in places. However, there are numerous places where buildings and trees are to be removed where inadequate survey has been carried out, which would result in a likelihood that many roosts as yet unidentified would be destroyed. This means the impact on bats cannot be properly assessed and appropriate compensation cannot be put forward.
For further information and images and to arrange interviews please contact :
Joe Nunez, Director of Communications and Fundraising.
E-mail: firstname.lastname@example.org Office: 0207 8207168
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